They have rendered the law meaningless within the construct of its own
twisted logic. Only a true bureaucrat could conclude any of this makes
sense, or that there is any point in proceeding with promulgation.
Syd H. Levine
AnaLog Services, Inc.
Phone: (270) 276-5671
Telefax: (270) 276-5588
E-mail: analog at logwell.com
Web URL: www.logwell.com
----- Original Message -----
From: "Clayton J Bradt" <cjb01 at health.state.ny.us>
To: <radsafe at radlab.nl>
Sent: Monday, February 04, 2008 10:57 AM
Subject: [ RadSafe ] NYC permitting of detectors: NYPD proposes some
changes.
NYPD is drafting some changes in the proposed law and has drafted proposed
regs. Below are the most relevant passages. I don't know if these have
been posted anywhere, I couldn't find them on the City Council web site, so
I'm just posting excerpts.
************************************
Proposed changes to Law:
§ 10-802 Permits for possession or deployment of biological, chemical and
radiological detectors. a. It shall be unlawful for any person to possess
or deploy a biological, chemical or radiological detector in the city of
New York unless such person holds a valid permit therefor, provided,
however, that the commissioner shall exclude by rule any class or type of
biological, chemical or radiological detector that shall not require such
permit because such detector does not have as a purpose the detection of a
possible biological, chemical or radiological weapons attack.
**************************************************
Proposed regulations:
§ 20-05 Exceptions.
Notwithstanding the provisions of Chapter 8 of Title 10 of the New York
City Administrative Code, no permit or notification of alarm is required
for the following types of detectors:
(a) Smoke alarms;
(b) Carbon monoxide detectors;
(c) Radon detectors;
(d) Hand-held or portable radiological detectors or Geiger counters
designed and intended for use by individuals; and
(e) Detectors which do not have as a purpose the detection of a
possible biological, chemical or radiological weapons attack, and include:
(i) Detectors possessed or deployed by an accredited academic
or instructional institution in an academic setting, whether in a
laboratory, classroom or in the field, by instructors or students, for the
purpose of academic instruction;
(ii) Radiation detectors possessed and deployed by hospitals
and other health care delivery settings, except for fixed portal radiation
detectors;
(iii) Detectors possessed or deployed by utilities or in an
industrial setting for the purpose of monitoring internal air quality or
leakage of hazardous materials; and
(iv) Detectors possessed or deployed by certified industrial
hygienists and other individuals or entities responsible for or engaging in
testing or monitoring of workplace or environmental safety.
***************************************************************************
As originally written, the law was outrageous and stupid. Now its just
stupid.
Clayton J. Bradt
Assistant Bureau Director
BERP
NYS Dept. of Health
518-402-7550
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